Politically Exposed Persons (PEPs) Policy

This PEPs Policy outlines how PROPERTIESLIBERIA.COM, LTD. identifies, verifies, and manages relationships with individuals classified as Politically Exposed Persons (PEPs).

Our goal is to reduce the risk of our platform being used for corruption, money laundering, or abuse of power by individuals in high-ranking public positions or their associates. This policy supports our broader Anti-Money Laundering (AML) commitment and is a core part of our onboarding and risk management process.

We don't discriminate against PEPs — we simply apply extra care, as recommended by global financial compliance standards.

A Politically Exposed Person (PEP) is an individual who holds, or has held, a prominent public position that could be abused for personal gain or used to facilitate illicit financial activities. This includes:

✅ Domestic and Foreign PEPs:

• Heads of state or government
• Senior politicians
• Senior military officers
• High-ranking members of the judiciary
• Members of parliament
• Senior executives of state-owned enterprises
• Ambassadors, consuls, and diplomatic figures

✅ Family Members and Close Associates (Known as "RCAs"):

• Spouses and partners
• Children and their spouses
• Parents and siblings
• Close business associates, advisers, or joint account holders with a known PEP

A person remains a PEP for at least 12–18 months after leaving their role and may still require enhanced monitoring beyond that period.

This policy applies to:

• All individual users of the platform
• Business entities applying for account creation or property listings
• Any real estate professionals or agents interacting with our payment systems
• Internal staff responsible for user verification or compliance

All users are subject to PEP screening at the time of onboarding, and certain high-risk cases may be reviewed on an ongoing basis.

📝 Self-Declaration:

As part of the sign-up or onboarding process, users must answer the following question:

If the user answers YES, their account is flagged for manual review.

🔍 Screening Tools (Optional/Advanced):

We may periodically supplement self-declaration by checking names against global PEP databases such as:

• Refinitiv World-Check
• Dow Jones Risk & Compliance
• OFAC & UN Consolidated Lists (if PEPs are also sanctioned)

For now, we rely on a declaration-based process but may integrate automated screening tools as we scale.

If a user is identified as a PEP, we carry out Enhanced Due Diligence (EDD), which includes:

• Collecting more details about their current or former public role
• Understanding the purpose of their use of the platform (e.g., property rental, sale, or business listing)
• Verifying the legitimacy of the source of funds for any transaction
• Consulting with senior management before final approval

Depending on the level of risk, we may:

• Allow access with tighter monitoring
• Request further documents
• Decline the relationship if the risk is too high

All EDD actions are recorded and stored securely for accountability.

PEPs may not always disclose their status, or their circumstances may change over time. That's why we:

• Periodically review high-risk or flagged accounts
• Monitor news alerts and politically exposed databases
• Reassess status if new information arises (e.g., user becomes a minister or leaves public office)

Users are required to inform us of any significant changes to their political exposure or affiliations.

We maintain a full audit trail of:

• All PEP self-declarations
• Enhanced due diligence actions
• Decisions made and any communication related to PEP status

These records are retained for a minimum of 5 years after the user stops using the platform. They are stored securely and accessible only to authorized compliance personnel.

This PEP Policy is reviewed at least once a year by management or when there are:

• Major changes to PEP compliance standards
• New risk exposure (e.g., political shifts in Liberia or globally)
• Feedback or requirements from our financial partners (e.g., MTN Mobile Money)

Updates are logged and shared with relevant team members. Any changes will also be reflected in our Terms and Compliance documents if they affect users.